For the Fall 2013 National Organic Standards Board (NOSB) meeting, Consumers Union’s Consumer Safety and Sustainability Group submitted 12 written public comments.

The NOSB is a 15-member citizen advisory panel charged by Congress with assisting and advising the Secretary of Agriculture on federal organic policy and rulemaking. Decisions made at the NOSB level affect which synthetic inputs and ingredients will be allowed in organic foods, how these decisions will be made, etc. Consumers Union’s role in watchdogging the NOSB is therefore critical to preserving the integrity of the organic label.

Consumers Union commented on the following NOSB proposals and discussion documents:

- Streptomycin: Antibiotics are prohibited in organics, with organic apple and pear orchards as the only exception. Consumers Union urges the NOSB to phase out the use of the antibiotic streptomycin -- the last remaining antibiotic allowed in organics -- in all organic orchards.

- Methionine: Consumers Union urges the phase-out of synthetic methionine in organic poultry feed. We opposed a proposal that would potentially increase levels of the synthetic amino acid in the feed of young laying hens.

- Aquaculture: The USDA does not have standards for organic fish, although standards that would include open ocean fish farms have been recommended by a past NOSB vote. Consumers Union believes that open ocean fish farms are potentially damaging to the marine ecosystem by creating water pollution from fish waste, excess feed and dead fish. Fish grown in open ocean fish farms should not be certified “organic.” We opposed four petitions for synthetic materials in organic aquaculture, pointing out that materials should not be approved until aquaculture standards are in place.

- Ammonium Hydroxide: This synthetic chemical was petitioned for use in water boilers, including water boilers used to pasteurize milk. Ammonium hydroxide is the same chemical used to kill bacteria in “pink slime.” We urged the NOSB to continue prohibiting its use in organic processing.

- Conflict of Interest: In order to maintain organic integrity and continued consumer trust in the organic label, Consumers Union urges the USDA’s National Organic Program (NOP) and the NOSB to collaborate on a sound definition of conflict of interest for NOSB members and a clear set of standards for determining recusals during votes. We stressed the point that NOSB members are advisors who should act in the interest of the organic community and the public at large, rather than in the interest of a special interest group (i.e., organic processors).

- Confidential Business Information: We supported the proposal to discontinue allowing companies to withhold information about their production practices in NOSB petitions.

- Research Priorities: Consumers Union offered to conduct research into consumer expectations regarding organics, as requested by the Materials Subcommittee.

- Gellan Gum: The NOSB requested information to determine whether gellan gum, a non-organic ingredient that is the product of bacterial fermentation and is currently approved for use in organic foods, should continue to be allowed. Consumers Union’s research revealed that scientists have experimented with genetic engineering of the bacterium to increase gellan gum production, and we urged the Board to determine whether non-GE varieties remain available before re-approving its use in organics.

- Tragacanth Gum: This non-organic ingredient is currently allowed in organic production, but an organic version (gum arabic, which according to the original petitioner is nearly identical to tragacanth gum) is available. When organic version are available, Consumers Union believes they should be used and the non-organic version should be prohibited.

- Glycerin: Consumers Union supported a petition to remove non-organic glycerin from the list of allowed substances, since an organic version of glycerin is now commercially available.

- PGME: The NOSB requested input on whether the boiler water chemical PGME should be reviewed and approved before allowing its use in organic feed production. Since PGME is a synthetic, Consumers Union urged the NOSB to ensure proper review and approval.